SecProbe.io

CORRESP
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corresp

November 7, 2005

VIA EDGAR AND FACSIMILE

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Visual Networks, Inc.

    Registration Statement on Form S-3

File No. 333-128145

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933,
a request is hereby made on behalf of Visual Networks, Inc. (the “Company”) that acceleration of
the effective date of the above-captioned Registration Statement be granted by the Securities and
Exchange Commission (the “Commission”) in order that the Registration Statement shall become
effective at 9:00 a.m. on November 9, 2005, or as soon thereafter as practicable.

In this regard, the Company acknowledges that:

    •

    should the Commission or the staff, acting
pursuant to delegated authority, declare the
filing effective, it does not foreclose the
Commission from taking any action with respect to
the filing;

    •

    the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the
filing effective, does not relieve the Company
from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and

    •

    the Company may not assert this action as a
defense in any proceeding initiated by the
Commission or any person under the federal
securities laws of the United States.

    Sincerely,

VISUAL NETWORKS, INC.

    By:
    /s/ Lawrence S. Barker

    Lawrence S. Barker

    President and Chief Executive Officer

and Chairman of the Board of Directors